A Critical look at the City of L.A.'s Water Supply Policy

Interested in identifying your California Groundwater Basin? I downloaded California Department of Water Resources groundwater basin .shp file and started a mini project converting it to a .kml file and colorizing each basin so that you could view them in Google Earth. The result is a beautiful colorful maze of groundwater basins throughout California.

In a city with nearly 4 million people, there are probably just a few dozen that even know what the Urban Water Management Plan is and even fewer that knew March 16th was the last day to comment on it. Comments that are submitted during the public comment period are published near the end of the UWMP and for the most part go unseen by the general public and decision makers such as the LADWP Board of Commissioners, the Los Angeles City Council and Mayor who deliberate over the plan and approve it. Perhaps the Los Angeles Department of Water and Power prefers it that way.

Having watched this process in 2010 and again in 2015, I am a bit surprised and dismayed that the local print media such as the Los Angeles Times and the Daily News don’t really report on the UWMP especially given how distressed our water supply situation is. They do often report on the shortage and water wasters. A quick search of the www.latimes.com and www.dailynews.com web sites for “urban water management plan”, I could find no evidence that either paper had reported anything about the city’s most important planning document.

This lack of coverage by our print media on the city’s UWMP is a real disservice to its residents. It’s also a disservice to our elected officials who I found have very little understanding of the water supply figures in this document. If the media would question them on it perhaps city officials would take this process more seriously. Elected and appointed city officials typically just approve documents like this, even seriously flawed UWMP's without much discussion because they don’t understand it.

The 2015 Draft UWMP is totally inadequate in its current form. It mischaracterizes the city’s true water supply outlook and needs to be rewritten to include meaningful, measurable, achievable water supply projections that planners, developers, and residents can be assured the department can meet.

As a service to our local media, I've posted my comments to the draft here. This would be a good place to start should you choose to report about the upcoming deliberations on the UWMP over the next few months.

With the Water Year ending last September, this is a look at the Los Angeles Aqueduct supplies from 1975 to 2015. Most of the hard reductions were due to Courts ordering the LADWP to permanently release water back into the Mono and Owens Basins between 1985 and 2007 . The last three years have been due primarily to the State's drought. Hopefully that will rebound back to the new normal of 210,000 to 220,000 AF levels over the next year or two.

When the LADWP uses paper water, not only does it affect Los Angeles residents, it also impacts utilities and residents outside of the city. 'Paper water' is water that “utilities claim they have access to, but is difficult or impossible to access for various reasons”.

When the LADWP claims to have access to more city owned domestic water than it really has access to, that allows the department to understate how much water it needs from the Metropolitan Water District.

Using paper water to prop up the perception of its domestic supply, the 2000 UWMP* suggested that the LADWP would only need to purchase and additional 3.53 million acre-feet of water between 2000 and 2015.

However the department was unable to follow through on its claims. Only 4 times in 16 years did the department meet its own projections. Over the other years it had to purchase 47% more water from the MWD amounting to 5.20 million acre-feet at a greater unit cost.

This is one of the ways that the department hides the water shortage in the EIR's that work their way through the planning process to shield development.

Obviously this practice would impact the MWD's operations to store surplus water as a hedge against drought in its Diamond Valley Reservoir and at Lake Mead.

*I used the 2000 UWMP because it presented a larger sample size of MWD purchases than later plans would. Later UWMP's use paper water similarly.

If there ever was a reason for the State Department of Water Resources to vet UWMPs that are submitted to it, this should be one of them. For 30 years, the Los Angeles Department of Water and Power’s practice of reporting water that it can't access has undermined public transparency, making it appear that the city water supply was well situated for growth. The city’s long, persistent drought is a result of this activity. Allowing utilities (LADWP is not alone) to report access to water they have no access to makes a mockery out of the so-called ‘Show Me the Water Laws’ and the State's water laws in general.

The practice threatens water supply because once development is permitted using fictitious future supply data, the predictable shortages appear which have to be followed by hard choices when other equally important users feel the impact and assert their rights. Who should make the sacrifice? Agriculture? Fish? Hydropower? The environment? Perhaps we should connect growth with water and make the cuts there.

Urban Water Management Plans should be clear and easy to understand and accessible to the public. When shortages are projected, the UWMP should also offer enough detail to decision makers and the public what the economic costs and access to water will be if development continues over the 20 year lifetime of the plan. More important than knowing there will be 611,800 AF/y in 2020, residents should be advised on how it will affect their monthly allocations and how much higher their billing costs will go up.

Today's Urban Water Management Plans are written in wonkish, 'members only' style that excludes public participation in its formation and approval of the document. The style also excludes the public from the planning process where it is ultimately used. I know that many planners and decision makers don't understand the document. They instead look to the singular paragraph in the EIR that says...

After spending a few weeks paging through the just released LADWP 2015 Draft Urban Water Management Plan, my immediate conclusion is that the plan is a thinly disguised effort to hide the city’s low water supply levels from the planning process to protect development.

This draft, like past UWMP’s, continues to project levels of water in all supply categories that the department does not have access to and it continues to assert access to water in categories that aren’t really a supply such as Conservation and Harvesting.

California law requires that utilities update the UWMP every five years to demonstrate long term water supply availability before approving new projects. This task has become tougher to prove as the regions grow and various interests throughout the state assert their rights to the state’s water supply. The department compounds the problem even further when it reports to planners and developers that there is sufficient water for growth despite the shortage.

In 2010 the LADWP found that totaling up aqueduct, groundwater, recycled water and MWD water was no longer adding up to the total supplies it needed to show as evidence of sufficient growth. To solve this problem, it began to look for new ways to produce water. Some categories were real such as stormwater capture and indirect potable reuse but other categories were simply fuzzy water meant to artificially raise the total supply using paper water.

A Line-by-Line look at the Future Water Supply Projections

The following is a line by line look at the supply projections in the draft's Service Area Reliability Assessments table. I’ll show where the real water is and what’s vulnerable to challenge.

Conservation

I’m going to be blunt. Conservation is not a supply. Conservation should be used to lower the baseline demand and from there, the department should demonstrate how it will meet that. However, the department uses Conservation as a supply to merely to bump up the total supply figures shown in the Service Area Reliability Assessment tables to present a UWMP that's favorable to planning documents.

The department’s 2015 draft shows Conservation as an existing or planned supply that will contribute up to 125,800 Af/y to the city’s water portfolio. But simply put, this is ‘paper water’. This is done to hide a portion of the total shortfall the department doesn’t want seen in Environmental Impact Reports that are attached to projects for review by the planning department.

There is a simple test to see if Conservation (or any other category of water) is real water or imaginary water. The 2009 California Water Plan Update describes ‘paper water’ as water that “utilities claim they have access to, but is difficult or impossible to access for various reasons”.

Using that definition in our test, if we eliminate all of the city’s real incoming sources of water such as the aqueduct, groundwater, recycled water, stormwater, and MWD water, and leave the city with only Conservation, how much water would the city have access to and available to use?

None. The leftover 125,800 AF of 'water' the LADWP claims it has access to is not accessible. You can’t wash your hands with this water and you cannot sip it from a glass. Consequently, it's paper water and not a supply.

Asserting that ‘Conservation’ is a water supply allows the department to manipulate the UWMP's supply projections, making it appear that the city’s total available supply will be 611,800 Af/y in 2020 and grow as high as 675,700 Af/y by the year 2040.

However, when we remove this imaginary water from the table, the departments total projections fall to a dismal 536,370 Af/y and over time it grows to just 600,770 AF/y by 2040. This is would fall more in line with the city’s historical supply.

I’m sure the department sees another benefit to asserting that Conservation is a supply. It doesn’t have to report the actual results like it does with real water from the aqueduct, groundwater, MWD, and recycled water which are all measured as they enter the water system.

Putting Conservation on the supply side of the equation creates a fuzzy math scenario of future water supply that does not belong in documents that rely on the UWMP. The department is basically saying, ‘IF the public reduces it gallons per capita daily by 50%, that’s like increasing the supply to 638,235 AF/y’ or ‘IF the public could meet 100% of the city’s projected conservation level, that would be the same as reaching 675,100 AF/y.’

Prior to 2010, the city had always deducted conservation savings from the baseline demand side and calculated the required supply from there. If it did this here, the projections would be in the range of 536,370 to 600,770 AF/y. The department would then have to provide a plan to explain how it will get the city to reduce its per capita supply from 130 gallons per day to just 95 gallons per day.

Aqueduct

The next supply item in the planned supply table is the Los Angeles Aqueduct. Sadly, the LADWP no longer finds William Mulholland’s engineering marvel worthy of top billing anymore. Instead it appears that the department wants optics on something called ‘Conservation’ in the UWMP even though that’s not real water like the aqueduct. It’s important to note that the Los Angeles Aqueduct continues to be the city’s largest owned producer of water in the city’s supply portfolio.

This item in the Draft 2015 UWMP uses paper water in the Los Angeles Aqueduct projections to hide 68,030 to 85,730 AF/y of the city’s total supply shortage.

The draft does this by seriously over estimating how much water is available through the aqueduct.

It’s nothing new however. The departments past UWMP’s had projected upwards of 380,000 acre feet of water per year entering the system. This draft cites up to 293,400 Af/y is still far more than the aqueduct’s actual average supply of just 207,670 AF/y between 2007 and 2012. (To be fair, I’ve purposely excluded the last three years due to the recent drought.)

There is no reason to believe that future aqueduct supplies will average higher than 227,000 Af/y even if the department is able to lower the amount of water needed to mitigate Owens Basin dust levels.

Groundwater

The next major source of water supply and third on the list is Groundwater. Like every UWMP before it, the Draft 2015 UWMP continues citing far more access to groundwater than the department really has access to.

This conclusion is made by comparing the actual measured groundwater supply that has averaged just 74,390 AF/y between 2000 and 2015 with the departments Draft 2015 UWMP projections of 112,670 to 114,070 AF/y. Anything more than 74,390 AF/y is paper water which is used to bump up the total supply and hide the departments shortage in planning documents.

From a historical perspective, there is simply no evidence that the department will meet the projections they cite in the current draft. Claims of over 100,000 AF/y have been made in every iteration of the departments UWMP since 1985.

Recycled Water – Irrigation and Industrial

Recycled water is next in the planned supply table in the Draft 2015 UWMP. The department split Recycled water is split between two sub categories back in 2010 and that continues today. They are ‘Irrigation and Industrial Use’ and ‘Groundwater Replenishment’.

Irrigation and Industrial Use, better known as purple pipe is expected to contribute 19,800 AF/y of water into the city water system by 2020 and increase to 45,400 AF/y by 2040. However, the departments history of meeting purple pipe projections suggests that they will not come close to meeting these new projections either. Over the last eight years the department’s average has been just ~7,500 AF/y.

EIR’s produced between 2010 and 2015 have all claimed that by 2015, water recycled and distributed through purple pipe would be contributing 20,000 Af/y into the city’s water system.

However, the department missed that mark badly with only ~9,800 AF of measured supply by September of 2015. Earlier UWMP’s promised even more water, citing that up to 29,000 AF/y would have been available by 2015.

Even given the chance that the LADWP might eke out at least 15,000 AF/y of purple pipe water, the Draft 2015 UWMP is effectively be hiding up to 30,400 AF/y of the city’s total supply shortage using paper water in this particular category.

Recycled Water – Groundwater Replenishment

Our fifth line of the planned supply table is Groundwater Replenishment. This is not expected to begin contributing the city’s water portfolio until 2025. Groundwater Replenishment is a treated wastewater program known as Indirect Potable Reuse which is similar to Orange County’s successful IPR program.

If the department is successful at rolling out IPR, this may turn out to be a real supply. How much we actually see entering the system on a year to year basis remains to be seen.

Stormwater Capture – Harvesting

What was new to the 2010 UWMP but considered only a ‘potential supply’, Stormwater Capture has been undeservingly upgraded to a ‘planned supply’. It is split between two line items, Stormwater ‘Reuse’ and Stormwater ‘Recharge’.

Stormwater Reused is the sixth supply line item in the planned supply table. Also known as Capture and Reuse or Harvesting, it is another fuzzy water category consisting of Rain Barrels and Cisterns. The department claims that these components will be contributing to 400 AF/y to the city’s water system by 2020 and that will increase to 2,000 AF/y by 2040.

In the previous 6 years, the 2010 UWMP asserted that Harvesting would contribute 2,000 to 10,000 AF/y of water into the city’s water supply portfolio but none of that was ever reported.

Development projects throughout the city parroted that claim in their EIR’s but the department could never measure it nor report it.

Whether it’s the 2010 UWMP or the 2015 plan, this category fits the definition of paper water because the department has no direct access to it.

Rain barrels and cisterns are back yard, privately owned containers that do not have gages mounted to them that report back to the utility. There is no way the LADWP can tell if they are actually in use, whether they’ve collected rainwater or if they have been repurposed for other uses. I get the sense that they are keeping this category around mainly so that they can give away rain barrels to promote the conservation.

The Draft 2015 UWMP uses paper water in the Stormwater Reuse category to hide 400 to 2,000 AF/y of the city’s total supply shortage.

(Correction: The graph and analysis in this section incorrectly cited the Single Dry Year table of 100 to 400 AF/y when Average Year Table was meant to be used. The level of paper water in this section was raised to 400 to 2,000 AF/y - 3/3/2016 dcoffin)

Stormwater Capture - Recharge

The seventh line item of the UWMP planned supply table is ‘Recharge’. Over the years the city has relied on ‘natural recharge’ but this has severely decreased due to the city’s urbanization because as structures and roads were built over permeable soil.

The intent is to build an infrastructure that will capture up to 15,000 AF/y of water during intense rainwater events and allow it to infiltrate into to the ground much like natural recharge.

This may very well be another form of supply that is difficult to access given that is relies on rain events. For example, El Nino was thought that it would bring heavy rains to the Los Angeles area in the Winter/Spring of 2016 but that did not happen.

Recharge will be subject to the same meteorological events that groundwater pumping relies on and as noted earlier, groundwater pumping has never met the long term projections found in past UWMPs. There is no guarantee that it will result in 15,000 Af/y supply until the program is in fully implemented and effects can be measured as it enters the city’s water system. How much we actually see entering the system on a year to year basis remains to be seen.

MWD Water Purchases with Existing/Planned Supplies

‘MWD Water Purchases’ is an interesting category because the department has consistently ‘underestimated’ how much it will buy from the Metropolitan Water District. This happens because as previously noted, the LADWP claims it has access to water it doesn’t have access to. Sooner or later the department has to quietly make adjustments and purchase additional water from the MWD to make up for the shortage.

The 2015 projections are pretty stunning given that it represents a 68% drop from the 2010 UWMP and worse, an 80% drop from the real purchases.

Given how much paper water is in this draft UWMP which includes the so-called ‘Conservation’, there is no evidence that the LADWP will be able to meet those projections and subsequently limit MWD purchases at this level unless Mayor Garcetti wants to deliberately deepen the city’s water supply shortage by plunging the city into a Phase IV or Phase V restrictions.

Between 2000 to 2010, the LADWP projected it would be purchasing an average of 247,995 AF/y from the MWD. But during this time the actual average supply it purchased from the MWD during that time was 30% higher at 325,570 AF/y.

This clearly demonstrates that the LADWP has not been meeting its real water projections and that its projections are indeed full of paper water. The department’s MWD projections are simply not reliable.

Transfers

Over the last six years, projects working their way through the planning process cited in their EIR’s that 40,000 AF/y of Transfer water would be available to the city by 2015 along with other surplus water in the other categories. However, the department was not able to access this water that so we can firmly place this in the category of paper water.

With the water market turning increasingly bleak, the LADWP rightfully did not include Transfers in the Service Area Reliability Assessments table as a ‘Planned Supply’. Instead it downgraded Transfers to a ‘Potential Supply’ but it still remains on the Service Area Reliability Assessments table making it ‘appear’ as if it is accessible.

The chances that the department will have access to this water is fairly remote given that there no willing sellers in the Central Valley or Northern California and its like that the department would find itself bidding against the well-financed Metropolitan Water District.

The $40 million spent by the LADWP on the Neenach Pumping Station Turnout Facility Project in the Antelope Valley doesn’t seem like a great investment today.

MWD Water Purchases with Existing/Planned Supplies and Transfers

The tenth and last item in the Draft 2015 UWMP Services Area Reliability Assessment is an alternative MWD Water Purchase should the LADWP be able to secure contracts for water in the ‘Transfer’ category. It states that if the LADWP were to be able to secure contracts for 40,000 AF/y of Transfer water, this would result in lower MWD purchases amounting to ~20,630 to 35,430 AF/y.

Recently the LADWP Tweeted from @LADWP that its water main leak rate is less than half of the national average. However, the department's aging water main 'blowout' rate is up 62% from July 2013. Leaks have remained flat during that period.

With the close of the 2015 water year last September, it's time to step back and take a look at how well the LADWP met its first five year projections that came from the 2010 Urban Water Management Plan. EIR's winding their way through the planning department use this data to presumably assure us that there will be sufficient water supply in 5, 10, 15, and 20 years into the future.

So how did the 2010 UWMP fare in its first five years? Did the department meet their total supply projections? Did they meet the groundwater, recycle, transfers and stormwater projections? What does this mean for the new 2015 UWMP that is being drafted today and soon be released for public comment?

Let's take a look and compare this years water deliveries to the last two UWMP's.

A Look at the Total Supply

The following two charts show us the total supply entering the LADWP water supply system which includes all of the categories mentioned above.

It's not pretty. In both charts we find that the department has not been meeting the supply projections that EIR's routinely cite in the planning documents assuring the city of sufficient supplies. Supply levels are far below both the 2005 and 2010 UWMP projections and trending down. The failure to meet these projections while planning departments continue to green-light projects contributes heavily to the city's water shortage.

The next sections will tell us where the department is falling short in the city's water supply portfolio.

Source: Aqueduct

Having already been battered in 2013 and 2014, its hard to imagine the Los Angeles Aqueduct deliveries getting worse but it did. 2015 turned out far worse for the aqueduct as it's deliveries fell to a mere 31,766 AF for the entire year. As a point of reference, 25,000 AF would normally be considered an 'average month' prior to 2000.

The city's aqueduct is the largest city owned contributor to the city's water supply portfolio but in April, May and June it fell behind even recycled water! EIR's circulating through the city's planning department assured planners that by 2015 the city would be receiving 252,000 AF of aqueduct water each year.

Clearly the weather pattern over the Eastern Sierras in the last three years has had an effect on the aqueduct supply as it has averaged just 58,000 AF/y, but even if the department had maintained the 2000-2012 average supply levels, it would still be below the departments long term projections.

Aqueduct Grade: F

Source: Groundwater

Groundwater is the city's second largest city owned contributor to the water supply portfolio. After decades of consistently missing supply projections and losing what credibility it could have earned, the LADWP was forced to lower its projections by reducing it's groundwater projections by 62 percent. Having done that, for the first time in 16 years the department actually came out ahead in 2015.

But we can't get too excited. The department's average production since 2000 was just 74,000 acre feet per year which is far less than the assurances found in EIR's stating that the LADWP will produce an average yield of 96,000 acre feet per year by 2020 and climb to over 110,000 AF/y. Groundwater production is not a reliably consistent year-to-year source of supply when pumping exceeds the San Fernando basin's average recharge rate. One or more years of heavy pumping have to be followed by several years of reduced pumping to allow for the basin to recharge.

Groundwater Supply Grade: D

Source: Recycle

While the LADWP projected gains for recycled water in the ten's of thousands of acre-feet, it's success over the past two decades could only be measured in the hundreds of acre-feet. EIR's circulating through the city's planning department over the last five years assured planners that by 2015, recycled water would be contributing 20,000 acre-feet per year to the city's portfolio. However, the department didn't even come close with just ~9,800 AF entering the system. This year we found that the missed its 2010 UWMP 5 year milestone by over 50 percent.

Past UWMP's regularly projected that the department would produce over 30,000 AF/y and the latest 2010 plan raised this further promising planners 59,000 Af/y by 2035. The chance of this happening is as remote as seeing the department replace all its aging water mains by 2035.

The Department of Water Resources says that if utilities can't access water they say they have access to, this is called paper water.

Recycled Water Grade: D

Source: Transfers

EIR's circulating through the city's planning department assured planners that by 2015, water transfers of 40,000 acre feet each year would be contributing to the city's supply portfolio. The department constructed the $40 million Neenach Pumping Station Turnout Facility Project in the Antelope Valley to facilitate transfers of water from the Central Valley and Northern California but no sellers were found, no contracts were signed and the promised 40,000 AF never entered the system.

'Transfers' are sales of water rights between one entity to another. To effect a transfer the city would have to find willing sellers such as water agencies or farms with surplus water and sign contracts for 40,000 AF/y of water.

LADWP's Transfers certainly falls under the definition of paper water.

Interestingly, LADWP's entry into the water market puts it in direct competition with its main provider of imported water, the Metropolitan Water District.

Transfers - Grade: F

Storm Water Capture

Storm Water Capture is composed of two subcategories of water, Harvesting (Rain Barrels & Cisterns) and 'Increased Groundwater Production'. Of the two, that later is not scheduled to produce water until 2020.

Since the department created this category of water, EIR's have been assuring city planners that Harvesting will reduce the city's demand by 2,000 AF by 2015.

The problem with this category of water is that it never enters the city's water system and thus cannot be certifiably measured. This creates doubt to whether the 2,000 acre feet per year is real water or just paper water. When LADWP managers were questioned about this they admitted that they do not have the ability to physically measure this water and would instead rely solely on models.

I have serious doubts that models could withstand a legal test in courts if an EIR were challenged because there is no way of knowing how many of the rain barrels were distributed, how many are actually being used or repurposed and how much water they actually captured. Furthermore, it would take 11 million rain barrels to store 2,000 AF of water that roughly amounts to 27 rain barrels per single family household.

I firmly place Harvesting in the category of paper water.

Harvesting - Grade: F

Source: Conservation

EIR's circulating through the city's planning department assured planners that by 2015, the city would be receiving 8,178 acre feet of water per year categorized as Conservation. However, Conservation is not a source. Water supply entering the city water system cannot be counted twice. New water comes into the city system as groundwater, recycled water, or imported water through the aqueduct and MWD.

When residents make a concerted effort to conserve and the resulting savings is redirected elsewhere, this doesn’t add to the supply, it merely stretches out the supply or allows it to be re-allocated to other uses such as new construction. Double-dipping is not a legal accounting method.

If the LADWP wants to demonstrate to the public how much the savings is made by conserving, it needs to put this on the demand side of the equation by reducing the gallons per capita daily. Until then this is just another form of paper water.

Conservation - Grade: No grade. Not a supply

Summary

Given how important it is to meet the assurances that planning documents such as Environmental Impact Reports cite, we would have to assign an 'F' grade to the LADWP for failing to meet its own water supply projections.

One might think today that the city's shortage is just a recent phenomena, it isn't. Here is what the LADWP's updated record looks like going back to 1990.

It’s bad enough that water utilities project far more supplies than they have access to which by definition is paper water. It's bad enough that using this imaginary water they always come to conclusion that every project requesting a WSA has sufficient water to proceed.But recently it became clear to me that are other forms of paper water that comes in large amounts as well. Paper water by definition is water the city says it has available to it, but it can never access because it’s being used by someone else within the state's water system.

In July I was asked by the Banning Ranch Conservancy to look at the Newport Banning Ranch water supply assessment as they prepared for a California Coastal Commission meeting on the project. Having reviewed quite a number of Los Angeles Department of Water and Power water supply assessments I knew the first place to look for paper water would be in found in the utilities projections. Over time I've suspected there were other areas where paper water could be found but L.A.’s sheer size made it difficult for me to validate those.

Reviewing this projects WSA was a good opportunity for me because it is more typical of WSA’s that are produced throughout Southern California and the city’s relatively small population also made it easier to see whether housing growth can contribute to paper water ‘surpluses’ under SB 610.

For a little background, the Newport Banning Ranch (NBR) project is a proposed 1,375 housing unit development in the City of Newport Beach that also includes commercial. The city’s water supply is quite a different from the City of Los Angeles's water supply in that groundwater clearly is a substantial portion of the city's water supply. Newport Beach does not have its own domestic ground water supply underfoot but instead it has four wells that are located are located about five miles away in Fountain Valley which are managed by the Orange County Water District. When ground water is in short supply the city buys imported water from MWDOC.

When I dug into the Newport Banning Ranch WSA I found it was similar to the water supply assessments that are routinely produced by the LADWP. The Newport Beach water supply assessment relies heavily on 'paper water' to create a façade of surplus water just like L.A.'s water supply assessments. When reviewing the city’s sources of water supply, I found that they never met their respective supply projections and there was no chance that they ever would. 21 percent of the city’s projected water supply was water that the city didn't have access to. Hence it was ‘paper water.’

Growth’s Contribution to Paper Water

But there was more. What about housing that doesn’t trigger SB 610 requirements for a WSA? Failing to report cumulative housing construction would be another form of paper water. If a WSA doesn’t acknowledge that new housing has been constructed since the city’s Urban Water Management Plan was approved, the water demand from the unrecognized housing would be viewed as a unused water that is still available for new projects.

The Newport Banning Ranch water supply assessment was based on an increase of just 1,039 housing units over 20 years. That figure came from the city’s Urban Water Management Plan which in turn comes from the RHNA allocations that are imposed on cities. A subject that I’ve written about extensively here.

Right off the top, the NBR project's proposed 1,375 units exceeds the city’s 20-year water plan by 336 units meaning that new water supplies should have been identified in the WSA.

But that led me to the next question. Aside from the fact that the project is larger the city’s projected housing growth, how many units were built in the city since 2005 that did not trigger a water supply assessment? The answer was stunning.

In just five years the city’s rise in housing exceeded the UWMP's 20-year projected growth by 380% or 5,017 units and there was still fifteen years to go. The extent of this growth really surprised me. I didn't expect that growth could be so under-projected in a UWMP that it would decidedly tip the scale towards insufficient supplies in just five years. Shouldn't a water supply assessment capture this demand on water supply? I think so. You can't say your Showing Me the Water if your not disclosing the demand.

Not surprisingly, the water supply assessment didn’t acknowledge this new housing so this water could be viewed as an unused surplus. The project's WSA simply ignored the new housing. Had it acknowledged that the city had grown, it may have created pressure on the developer to find new water supplies. The Show Me the Water Law is supposed to link large projects to water supply. It should also assure that large projects are not be claiming to have access to water already that has already been committed elsewhere.

SB 610’s silence on projects that are less than 500 units effectively guts the law. The law only says that a WSA must include a ‘discussion’ of various elements of the water supply such as total projected supply during normal and dry years. The law doesn’t explicitly point out that the discussion should include housing growth that was not accounted for in the UWMP. Another weakness in the law is that it doesn’t have any regulatory oversight. This leaves it up to citizens to have to challenge water supply as it appears in an EIR.

The law should be expanded to require cities to keep a running total of new demand for recently approved projects that do not trigger a water supply assessment and incorporate that into all EIR’s. And while its keeping a running total of demand, it should also inform citizens on what that increasing demand will do to their monthly water allocations and rates.

This would give decision makers a little more information that might help eliminate any water shortage surprises should the increase in projected housing exceed the projected increase in the UWMP.

NBR’s other Imaginary Water

Aside from the WSA’s failure to mention new water demand from the city's ongoing housing construction, there were other problems with the Newport Banning Ranch WSA.

The WSA suggested that the city’s water supply would increase from 18,648 AF a year to 21,716 AF/y. This suggestion would lead the city's decision makers to incorrectly believe that supplies are increasing which would be sufficient for the projects proposed new housing. However a review of the city’s historical supply tells us another story. That there's little chance that the city's future supply will ever exceed 17,200 AF year-after-year or that it will ever see supplies exceed 19,000 Af in any one year.

What I found was that the total well water supply was not enough to meet the UWMP projected supply. Since 1990, OCWD groundwater allocations have been averaging about 72 percent. In the last 10 years that figure has dropped to 62%.

The WSA also suggested that during droughts when wells weren't producing sufficient supplies, the city would be able to make up for those shortages by purchasing imported water from MWDOC. The WSA even goes so far to state that MWDOC "was able to show that it can maintain 100% reliability in meeting direct consumptive demand under condition that represent normal, single driest, and multi dry years through 2030". However, the fact is that MWDOC doesn’t have enough water available for purchase to meet the city’s 21 percent shortfall even in wet years which is shown by the gap in the chart at the right labeled 'paper water'.

All Claims of Sufficient Water Supply Should Be Considered Suspect

The Newport Beach WSA isn't unusual. I suspect it's typical of water supply assessments produced throughout Southern California and maybe even Central California as well. The ‘Show Me The Water’ law requires that a water supply assessment be attached to the projects EIR when the project is 500 units or larger. While small and medium size projects do not require a water supply assessment, CEQA still has a requirement for an analysis on water supply in the Utilities section of the EIR.

The EIR merely has to refer to the local utilities UWMP to serve as an assessment for these projects. Whether the discussion of water supply is found in the WSA or the UWMP, there is a nearly 100 percent chance that the utilities water supply includes a substantial amount of paper water. All claims of ‘sufficient’ or ‘adequate’ water supply should be reviewed closely.

Jack Black gets a lot right about L.A. Aqueduct's history in 6 minutes on this Comedy Central YouTube video.

Maybe they could also put together a Drunk History version behind LADWP's twisted logic that building 100,000 new units actually saves the city water! Come to think of it, that's a thoroughly modern day version of China Town.